Russia Presidential Decree 1012 places Canpack's Russian aluminium-can subsidiaries under StalElement LLC temporary administration

Mechanism

Decree No. 302 (25 April 2023), "On temporary management of certain property," is Russia's standing legal instrument for placing Russian-based property of companies from "unfriendly" jurisdictions under state administration. It operates by an ever-growing schedule/annex: the President periodically signs a short amending decree that adds specific named companies' shares or assets to the list. Decree No. 1012 is one such amendment — signed 31 December 2025 but not officially published (and therefore not in force) until 13 January 2026 — adding 100 percent of the authorized-capital shares of Can-Pak LLC (belonging to Poland's Canpack S.A.) and Can-Pak Packaging Plant LLC (belonging to Tapon France) to the Decree 302 schedule, and naming StalElement LLC as the temporary administrator.

Unlike the earlier Fortum, Air Liquide and Silgan additions to the same list, which handed administration to the state property agency Rosimushchestvo directly, this decree routes control through StalElement LLC, a specially constituted private administrator — consistent with a pattern (also seen in the same-day Rockwool decree, routed to "Razvitie Stroitelnykh Aktivov") of using purpose-formed entities rather than Rosimushchestvo itself for newer seizures.

Downstream implications

• Removes CANPACK Group's operational control of its two Russian

aluminium-can plants (Volokolamsk and Novocherkassk), a business reported at roughly $700m in value and 25-35% of the Russian aluminium-can market — control passes to Kremlin-appointed managers at StalElement.

• Same-day companion decree (No. 1010/1011 range, signed same batch)

placed Danish insulation maker Rockwool's Russian subsidiaries under a parallel administrator ("Razvitie Stroitelnykh Aktivov"), indicating a bundled year-end batch of Decree 302 amendments rather than a company-specific trigger.

• Extends the same two-stage risk pattern flagged in the Silgan/Vonorus

filing (2025-10-06-russia-decree-710-silgan-vonorus-temporary-administration): temporary administration typically precedes potential fast-track disposal to a state-directed buyer under Decree No. 693 of 30 September 2025 (2025-09-30-russia-decree-693-federal-property-fast-track-sale).

Open questions

• Whether Can-Pak's output (aluminium beverage cans) is redirected to

in-country beverage bottlers under StalElement, and whether CANPACK Group recorded an impairment on the Russian units.

• Whether StalElement LLC is linked to any other Decree-302 administrator

entities or ultimate beneficiaries, and whether the assets are eventually routed through the Decree 693 fast-track sale mechanism.